Carlson v. Carlson

This is an appeal by a mother and an adoptive father from an order allowing their child’s maternal grandmother limited visitation rights with her granddaughter. The primary question presented is whether, pursuant to the provisions of RCW 26.09.240, a maternal grandparent may be granted visitation privileges over the objection of the child’s natural mother and adoptive father.

Appellant Christine Spark (nee Carlson) gave birth to an illegitimate child on November 23, 1971. For the next 2 years, the child’s maternal grandmother (respondent) cared for the child during working hours. In 1974,…